Virginia Giuffre/Ghislaine Maxwell case composite depositions

COMPOSITE EXHIBIT 1 (Filed Under Seal) Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 1 of 40 www.Southernreporting.com - (386)257-3663 Southern Reporting Company 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE: 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. ____________________/ VIDEOTAPED DEPOSITION OF TONY FIGUEROA Volume 1 of 2 Pages 1 - 157 Taken at the Instance of the Defendant DATE: Friday, June 24, 2016 TIME: Commenced: 8:59 a.m. Concluded: 1:22 p.m. PLACE: Southern Reporting Company B. Paul Katz Professional Center (SunTrust Building) One Florida Park Drive South Suite 214 Palm Coast, Florida 32137 REPORTED BY: LEANNE W. FITZGERALD, FPR Florida Professional Reporter Court Reporter and Notary Public Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 2 of 40 www.Southernreporting.com - (386)257-3663 Southern Reporting Company 96 1 Q I guess my question is: Did she ever tell 2 you that she had started as a regular masseuse for 3 him and then transitioned to something other than a 4 masseuse? 5 A No. She never said that it transitioned. 6 But she ended up explaining to me what had happened 7 before, so... 8 Q What has -- what is that? 9 A That her and Ms. Maxwell and Jeffrey would 10 obviously be doing stuff, all three of them 11 together. Like I said, that they would all go out 12 to clubs to pick up girls and try and find them to 13 bring back for Jeffrey. And then she told me about 14 how, like I said, her and Ms. Maxwell and Jeffrey 15 were all intimate together on multiple occasions. 16 Q When did she tell you this? 17 A I'm not exactly sure on the dates. 18 Q Was it while you were still together? 19 A Yes. 20 Q Did you -- had you met Ms. Maxwell? 21 A Yeah, I had met her a couple of times. 22 Q When did you meet Ms. Maxwell? 23 A Dates, I'm unsure of. But it was pretty 24 much, like I said, at Jeffrey's house in the 25 kitchen. Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 3 of 40 www.Southernreporting.com - (386)257-3663 Southern Reporting Company 97 1 Q Was it earlier in the time you were with 2 her, or... 3 A It was about -- I'd say about six months 4 or so. I don't know. I'm not exactly positive. 5 Q All right. So at the time you met 6 Ms. Maxwell, had Ms. Roberts already told you that 7 she had been intimate? 8 A No. She had told me about that, I 9 believe, after I had max- -- after I had already met 10 her. 11 Q Okay. And tell me everything that you 12 remember about what Ms. Roberts said about being 13 intimate with Ms. Maxwell and Mr. Epstein at the 14 same time. 15 A I remember her talking about, like, 16 strap-ons and stuff like that. But, I mean, like I 17 said, all the details are not really that clear. 18 But I remember her talking about, like, how they 19 would always be using and stuff like that. 20 Q She and Ms. Maxwell and Mr Epstein would 21 used strap-ons? 22 A Uh-huh (affirmative). 23 Q How did you feel about that? 24 A I just -- obviously not happy about it. 25 Q What did you say? Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 4 of 40 www.Southernreporting.com - (386)257-3663 Southern Reporting Company 103 1 A I did not. 2 Q When the FBI interviewed you, did you 3 mention this to them? 4 A I mentioned -- anything they asked me, I 5 did not hold anything back. 6 Q Okay. Do you recall specifically talking 7 about sex with the Prince? 8 A I -- I don't recall talking to them about 9 that, but, I mean, it's -- it could be possible. 10 Q Other than sex with the Prince, is there 11 anyone else that Jeffrey wanted Ms. Roberts to have 12 sex with that she relayed to you? 13 A Mainly, like I said, just Ms. Maxwell and 14 all the other girls. 15 Q Ms. Maxwell wanted -- Jeffrey wanted 16 Virginia to have sex with Ms. Maxwell? 17 A And him, yeah. 18 Q And did she tell you whether she had ever 19 done that? 20 A Yeah. She said that she did. 21 Q And when did she tell you that? 22 A I'm not sure on the date. 23 Q And what did she describe having happened? 24 A I believe I already told you that. With 25 the strap-ons and dildos and everything. Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 5 of 40 www.Southernreporting.com - (386)257-3663 Southern Reporting Company 200 1 MS. MENNINGER: Objection. Form. 2 Foundation. 3 A For Jeffrey. 4 BY MR. EDWARDS: 5 Q All right. Let me fix this. Ghislaine -- 6 when Ghislaine Maxwell would call you during the 7 time that you were living with Virginia, she would 8 ask you what, specifically? 9 MS. MENNINGER: Objection. Form. 10 Foundation. 11 A Just if I had found any other girls just 12 to bring to Jeffrey. 13 BY MR. EDWARDS: 14 Q Okay. 15 A Pretty much every time there was a 16 conversation with any of them, it was either asking 17 Virginia where she was at, or asking her to get 18 girls, or asking me to get girls. 19 Q All right. Let's go to that second 20 category you just identified, which is asking 21 Virginia to get girls. How many times were you in a 22 room where specifically Ghislaine Maxwell would ask 23 Virginia to bring girls? 24 A None that I can recall. 25 Q Okay. How many times -- when you say they Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 6 of 40 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x May 18, 2016 9:04 a.m. C O N F I D E N T I A L Deposition of JOHANNA SJOBERG, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 7 of 40 Page 8 1 Q. Okay. Great. 2 All right. Do you know a female by the 3 name of Ghislaine Maxwell? 4 A. Yes. 5 Q. And when did you first meet Ms. Maxwell? 6 A. 2001. March probably. End of 7 February/beginning of March. 8 Q. And how did you meet her? 9 A. She approached me while I was on campus at 10 Palm Beach Atlantic College. 11 Q. And what happened when she approached you? 12 A. She asked me if I could tell her how to 13 find someone that would come and work at her house. 14 She wanted to know if there was, like, a bulletin 15 board or something that she could post, that she was 16 looking for someone to hire. 17 Q. And what did you discuss with her? 18 A. I told her where she could go to -- you 19 know, to put up a listing. And then she asked me if 20 I knew anyone that would be interested in working 21 for her. 22 Q. Did she describe what that work was going 23 to be? 24 A. She explained that she lived in Palm Beach 25 and didn't want butlers because they're too stuffy. Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 8 of 40 Page 9 1 And so she just liked to hire girls to work at the 2 house, answer phones, get drinks, do the job a 3 butler would do. 4 Q. And did she tell you what she would pay 5 for that kind of a job? 6 A. At that moment, no, but later in the day, 7 yes. 8 Q. And what did she say? 9 A. Twenty dollars an hour. 10 Q. Was there anybody else with Ms. Maxwell 11 when you met her? 12 A. There was another woman with her. I don't 13 recall her or what she looks like or how old she 14 was. 15 Q. And what happened next? 16 A. And then she asked me if I would be 17 interested in working for her. And she told me that 18 she was -- I could trust her and that I could jump 19 in her car and go check out the house at that moment 20 if I wanted. 21 And so I said, Sure, let's do it, and went 22 to her home with her. 23 Q. And where was that home? 24 A. In Palm Beach. 25 Q. And did she describe that home as being Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 9 of 40 Page 13 1 Q. And how long did you work in that position 2 answering phones and doing -- 3 A. Just that one day. 4 Q. Just that one day. 5 And did your duties change? 6 A. Well, the next time she called me, she 7 asked me if I wanted to come over and make $100 an 8 hour rubbing feet. 9 Q. And what did you think of that offer? 10 A. I thought it was fantastic. 11 Q. And did you come over to the house for 12 that purpose? 13 A. Yes. 14 Q. And when you came over to the house, was 15 Maxwell present? 16 A. I don't recall. 17 Q. And what happened that second time you 18 came to the house? 19 A. At that point, I met Emmy Taylor, and she 20 took me up to Jeffrey's bathroom and he was present. 21 And her and I both massaged Jeffrey. She was 22 showing me how to massage. 23 And then she -- he took -- he got off the 24 table, she got on the table. She took off her 25 clothes, got on the table, and then he was showing Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 10 of 40 Page 33 1 MS. MENNINGER: Objection, leading. 2 BY MS. McCAWLEY: 3 Q. Do you believe that from your 4 observations, Maxwell and Epstein were boyfriend and 5 girlfriend? 6 A. Initially, yes. 7 Q. Did Maxwell ever share with you whether it 8 bothered her that Jeffrey had so many girls around? 9 MS. MENNINGER: Objection, leading, 10 hearsay. 11 THE WITNESS: No. Actually, the opposite. 12 BY MS. McCAWLEY: 13 Q. What did she say? 14 A. She let me know that she was -- she would 15 not be able to please him as much as he needed and 16 that is why there were other girls around. 17 Q. Did there ever come a time -- did you ever 18 take a photography class in school? 19 A. Yes. 20 Q. And did there ever come a time when 21 Maxwell offered to buy you a camera? 22 A. Yes. 23 MS. MENNINGER: Objection, leading. 24 BY MS. McCAWLEY: 25 Q. Did Maxwell ever offer to buy you a Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 11 of 40 Page 34 1 camera? 2 MS. MENNINGER: Objection, leading. 3 THE WITNESS: Yes. 4 BY MS. McCAWLEY: 5 Q. Was there anything you were supposed to do 6 in order to get the camera? 7 MS. MENNINGER: Objection, leading. 8 THE WITNESS: I did not know that there 9 were expectations of me to get the camera until 10 after. She had purchased the camera for me, 11 and I was over there giving Jeffrey a massage. 12 I did not know that she was in possession of 13 the camera until later. 14 She told me -- called me after I had left 15 and said, I have the camera for you, but you 16 cannot receive it yet because you came here and 17 didn't finish your job and I had to finish it 18 for you. 19 BY MS. McCAWLEY: 20 Q. And did you -- what did you understand her 21 to mean? 22 A. She was implying that I did not get 23 Jeffrey off, and so she had to do it. 24 Q. And when you say "get Jeffrey off," do you 25 mean bring him to orgasm? Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 12 of 40 Page 35 1 A. Yes. 2 Q. Did Ghislaine ever describe to you what 3 types of girls Jeffrey liked? 4 A. Model types. 5 Q. Did Ghislaine ever talk to you about how 6 you should act around Jeffrey? 7 A. She just had a conversation with me that I 8 should always act grateful. 9 Q. Did Jeffrey ever tell you that he took a 10 girl's virginity? 11 A. He did not tell me. He told a friend of 12 mine. 13 Q. And what do you recall about that? 14 MS. MENNINGER: Objection, hearsay, 15 foundation. 16 THE WITNESS: He wanted to have a friend 17 of mine come out who was cardio-kickboxer 18 instructor. She was a physical trainer. 19 And so I brought her over to the house, 20 and he told my friend Rachel that -- he said, 21 You see that girl over there laying by the 22 pool? She was 19. And he said, I just took 23 her virginity. And my friend Rachel was 24 mortified. 25 Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 13 of 40 Page 142 1 exposed her bra, and she grabbed it and pulled it 2 down. 3 Q. Anything else? 4 A. That was the conversation that he had told 5 her that he had taken this girl's virginity, the 6 girl by the pool. 7 Q. Okay. Did Maxwell ever say to you that it 8 takes the pressure off of her to have other girls 9 around? 10 A. She implied that, yes. 11 Q. In what way? 12 A. Sexually. 13 Q. And earlier Laura asked you, I believe, if 14 Maxwell ever asked you to perform any sexual acts, 15 and I believe your testimony was no, but then you 16 also previously stated that during the camera 17 incident that Maxwell had talked to you about not 18 finishing the job. 19 Did you understand "not finishing the job" 20 meaning bringing Jeffrey to orgasm? 21 MS. MENNINGER: Objection, leading, form. 22 BY MS. McCAWLEY: 23 Q. I'm sorry, Johanna, let me correct that 24 question. 25 What did you understand Maxwell to mean Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 14 of 40 Page 143 1 when she said you hadn't finished the job, with 2 respect to the camera? 3 MS. MENNINGER: Objection, leading, form. 4 THE WITNESS: She implied that I had not 5 brought him to orgasm. 6 BY MS. McCAWLEY: 7 Q. So is it fair to say that Maxwell expected 8 you to perform sexual acts when you were massaging 9 Jeffrey? 10 MS. MENNINGER: Objection, leading, form, 11 foundation. 12 THE WITNESS: I can answer? 13 Yes, I took that conversation to mean that 14 is what was expected of me. 15 BY MS. McCAWLEY: 16 Q. And then you mentioned, I believe, when 17 you were testifying earlier that Jeffrey told you a 18 story about sex on the plane. What was that about? 19 MS. MENNINGER: Objection, hearsay. 20 THE WITNESS: He told me one time Emmy was 21 sleeping on the plane, and they were getting 22 ready to land. And he went and woke her up, 23 and she thought that meant he wanted a blow 24 job, so she started to unzip his pants, and he 25 said, No, no, no, you just have to be awake for Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 15 of 40 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK - - - - - - - - - - - - - - - - - - - - x VIRGINIA L. GIUFFRE, Plaintiff, Case No.: -against- 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. - - - - - - - - - - - - - - - - - - - - x **CONFIDENTIAL** Videotaped deposition of RINALDO RIZZO, taken pursuant to subpoena, was held at the law offices of Boies Schiller & Flexner, 333 Main Street, Armonk, New York, commencing June 10, 2016, 10:06 a.m., on the above date, before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. - - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 16 of 40 Page 52 1 R. Rizzo - Confidential 2 Q. Did you learn whether your 3 perception was correct? 4 MR. PAGLIUCA: Same objection. 5 A. It was younger. Yes, I did. 6 Q. How old was this girl? 7 A. 15 years old. 8 Q. What happens next when Ghislaine 9 Maxwell and Jeffrey Epstein and a 15-year-old 10 girl walk into Eva Anderson's home? 11 MR. PAGLIUCA: Object to the form. 12 Foundation. 13 A. They proceed into the dining room 14 area, which is across from the living room 15 area. I go into the kitchen and I hear a 16 conversation start. Very muffled, I could 17 not hear any particulars about the 18 conversation whatsoever. 19 My wife and I are in the kitchen 20 preparing the evening meal. Eva brings the 21 young girl into the kitchen. In the kitchen, 22 there is an island with three barstools. Eva 23 instructs the young girl to sit to the 24 furthest barstool on the right. 25 Q. Describe for me what the girl Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 17 of 40 Page 53 1 R. Rizzo - Confidential 2 looked like, including her demeanor and 3 anything else you remember about her when she 4 walks into the kitchen. 5 A. Very attractive, beautiful young 6 girl. Makeup, very put together, casual 7 dress. But she seemed to be upset, maybe 8 distraught, and she was shaking, and as she 9 sat down, she sat down and sat in the stool 10 exactly the way the girls that I mentioned to 11 you sat at Jeffrey's house, with no 12 expression and with their head down. But we 13 could tell that she was very nervous. 14 Q. What do you mean by distraught and 15 shaking, what do you mean by that? 16 A. Shaking, I mean literally 17 quivering. 18 Q. What happens next? 19 A. We were, again, the absurdity, 20 never introduced. Like you would walk into a 21 room and say this is -- so my wife and I are 22 in the kitchen and this young girl is sitting 23 there. It was a very uncomfortable moment. 24 I look at my wife. And so I want to ease the 25 moment, and so I introduced myself and I Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 18 of 40 Page 54 1 R. Rizzo - Confidential 2 introduced my wife, and she doesn't really 3 respond. 4 And I asked her, are you okay? And 5 she doesn't really respond. Nothing verbal, 6 no cues, her head is still down. I ask her 7 if she would like some water, tissue, 8 anything, and she basically doesn't respond. 9 Q. You ask her for a tissue? 10 A. If she would like a tissue or some 11 water at the time. 12 Q. Was she crying at the time? 13 A. My perception, she was on the verge 14 of crying. And I'm trying to loosen the 15 situation every way I know how, so the only 16 way I knew how, and I thought maybe this will 17 comfort her, I said oh, by the way, do you 18 work for Jeffrey. 19 And she says that, I guess kind of 20 made her feel comfortable, because maybe it 21 was that comment or my persistence, and she 22 said yes. So I said, what do you do? And 23 she says I'm Jeffrey's executive assistant, 24 personal assistant. Which, from looking at 25 her, just didn't seem to suit. Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 19 of 40 Page 55 1 R. Rizzo - Confidential 2 And I blurted out: You're his 3 executive personal assistant? What do you 4 do? And she says I was hired as his 5 executive personal assistant. I schedule his 6 appointments. 7 And I'm shocked, and I blurt out: 8 You seem quite young, how did you get a job? 9 How old are you? And she says to me, point 10 blank: I'm 15 years old. 11 And I said to her: You're 15 years 12 old and you have a position like that? At 13 that point she just breaks down hysterically, 14 so I feel like I just said something wrong, 15 and she will not stop crying. My wife and I 16 were at a loss for words, and I keep on 17 trying to console her, and nothing I was 18 saying, are you all right, do you need a 19 tissue, do you need water, consoles her. 20 And then in a state of shock, she 21 just lets it rip, and what she told me was 22 just unbelievable. 23 Q. What did she say? 24 MR. PAGLIUCA: Object to the form 25 and foundation. Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 20 of 40 Page 56 1 R. Rizzo - Confidential 2 A. She proceeds to tell my wife and I 3 that, and this is not -- this is blurting 4 out, not a conversation like I'm having a 5 casual conversation. That quickly, I was on 6 an island, I was on the island and there was 7 Ghislaine, there was Sarah, she said they 8 asked me for sex, I said no. 9 And she is just rambling, and I'm 10 like what, and she said -- I asked her, I 11 said what? And she says yes, I was on the 12 island, I don't know how I got from the 13 island to here. Last afternoon or in the 14 afternoon I was on the island and now I'm 15 here. And I said do you have a -- this is 16 not making any sense to me, and I said this 17 is nuts, do you have a passport, do you have 18 a phone? 19 And she says no, and she says 20 Ghislaine took my passport. And I said what, 21 and she says Sarah took her passport and her 22 phone and gave it to Ghislaine Maxwell, and 23 at that point she said that she was 24 threatened. And I said threatened, she says 25 yes, I was threatened by Ghislaine not to Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 21 of 40 Page 57 1 R. Rizzo - Confidential 2 discuss this. 3 And I'm just shocked. So the 4 conversation, and she is just rambling on and 5 on, again, like I said, how she got here, she 6 doesn't know how she got here. Again, I 7 asked her, did you contact your parents and 8 she says no. 9 At that point, she says I'm not 10 supposed to talk about this. I said, but I 11 said: How did you get here. I don't 12 understand. We were totally lost for words. 13 And she said that before she got 14 there, she was threatened again by Jeffrey 15 and Ghislaine not to talk about what I had 16 mentioned earlier, about -- again, the word 17 she used was sex. 18 Q. And during this time that you're 19 saying she is rambling, is her demeanor 20 continues to be what you described it? 21 A. Yes. 22 Q. Was she in fear? 23 A. Yes. 24 MR. PAGLIUCA: Object to the form 25 and foundation. Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 22 of 40 Page 58 1 R. Rizzo - Confidential 2 Q. You could tell? 3 A. Yes. 4 MR. PAGLIUCA: Same objection. 5 A. She was shaking uncontrollably. 6 Q. What happens with this 15-year-old 7 girl next? 8 MR. PAGLIUCA: Object to the form 9 and foundation. 10 A. As she is trying to explain, and 11 I'm asking questions because I'm as feared as 12 she is at this point. We hear people 13 approach and she just shuts up. 14 Q. What happens next? 15 A. Eva comes in and tells her that she 16 will be working for Eva in the city. 17 Q. As what? 18 A. As a nanny. 19 Q. Did you see this girl again? 20 A. Yes. 21 Q. And when? 22 A. On a flight maybe a month or so to 23 Sweden. 24 Q. What was the purpose of the flight? 25 A. We were going to Sweden for the Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 23 of 40 Page 59 1 R. Rizzo - Confidential 2 summer. 3 Q. Who was on the flight? 4 A. The Dubin family. 5 Q. As well as this girl? 6 A. Yes. 7 Q. What happens? 8 A. One thing that I forgot to mention 9 is during our initial conversation, I asked 10 her what her name was she said her name 11 was . 12 Q. What happened with ? 13 A. We flew to Sweden, we stopped at an 14 airport that we didn't usually stop at and 15 she got off the plane. 16 Q. Just so that I make sure I 17 understand, who it was that she says asked 18 her for sex on the island, who was that? 19 MR. PAGLIUCA: Object to the form. 20 Foundation. 21 A. She didn't specify who asked for 22 sex. She said that they asked for sex. 23 Immediately after that she put Ghislaine and 24 Sarah into the conversation. 25 Q. Taking her passport? Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 24 of 40 Page 60 1 R. Rizzo - Confidential 2 A. Yes. 3 Q. From -- are there any other 4 incidents or occurrences that you observed 5 personally with Jeffrey Epstein and Ghislaine 6 Maxwell? 7 MR. PAGLIUCA: Object to the form 8 and foundation. 9 A. Not that I can recall. 10 Q. This last event that you described, 11 what's the timeframe when that occurred? 12 A. Late 2004, 2005. 13 Q. When did you resign your employment 14 from the Dubin family? 15 A. I think roughly October. 16 Q. Of what year? 17 A. 2005. 18 Q. Why? 19 A. My wife and I had discussed these 20 incidents, and this last one was just, we 21 couldn't deal with it. 22 Q. When you left your employment with 23 the Dubin family, did you have a job? 24 A. When we finally left, I stayed on 25 three months after my resignation, I had a Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 25 of 40 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 1, 2016 9:12 a.m. C O N F I D E N T I A L Deposition of JOHN ALESSI, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 26 of 40 Page 28 1 JOHN ALESSI 2 Q. And where did the massage therapists -- 3 where did they come from? 4 A. Most, they came from Palm Beach. Palm 5 Beach County. 6 Q. And over the course of that 10-year period 7 of time while Ms. Maxwell was at the house, do you 8 have an approximation as to the number of different 9 females -- females that you were told were massage 10 therapists that came to the house? 11 MR. PAGLIUSCA: Object to form and 12 foundation. 13 THE WITNESS: I cannot give you a number, 14 but I would say probably over 100 in my stay 15 there. 16 BY MR. EDWARDS: 17 Q. And many of the times would the females 18 come only one time and not return? 19 MR. PAGLIUSCA: Object to form and 20 foundation. 21 BY MR. EDWARDS: 22 Q. Let me ask that a different way. 23 Were there times when some of these 24 females that would come to the house, and you were 25 told that they were massage therapists, would come Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 27 of 40 Page 52 1 JOHN ALESSI 2 MR. PAGLIUSCA: Object to form and 3 foundation. 4 THE WITNESS: Himself. Himself. 5 BY MR. EDWARDS: 6 Q. And you do not know the ages of the 7 various massagists, right? 8 A. No. 9 Q. Did you have occasion to clean up after 10 the massages? 11 A. Yes. 12 Q. Okay. And that is after both a massage 13 for Jeffrey Epstein, as well as clean up after a 14 massage that Ghislaine Maxwell may have received? 15 A. Yes. 16 Q. And on occasion, after -- in cleaning up 17 after a massage of Jeffrey Epstein or Ghislaine 18 Maxwell, did you have occasion to find vibrators or 19 sex toys that would be left out? 20 MR. PAGLIUSCA: Object to form and 21 foundation. 22 THE WITNESS: Yes, I did. 23 BY MR. EDWARDS: 24 Q. Can you describe the types of vibrators or 25 sex toys that you found left out after a massage Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 28 of 40 Page 53 1 JOHN ALESSI 2 that Jeffrey Epstein had just received or Ghislaine 3 Maxwell had just received? 4 MR. PAGLIUSCA: Object to form and 5 foundation. 6 THE WITNESS: It was probably two to three 7 times, I would say. It was not all the time. 8 I would find things like a dildo, it's called a 9 double. I hate to say it because these ladies. 10 But I find these things, put my gloves on, took 11 it out and rinse it, and put it in 12 Ms. Maxwell's closet. 13 BY MR. EDWARDS: 14 Q. Why would you put the dildo or sex toy in 15 Ms. Maxwell's closet? 16 A. Because I knew that's where they were 17 kept. 18 Q. How did you know that the sex toys were 19 kept in Ms. Maxwell's closet? 20 A. Because I know where everything was in 21 that house. Every single room, every single thing, 22 it was a place, it was placed by me, by the cleaning 23 lady or my wife. Every -- everything that happened 24 in that house, I knew it. 25 Q. Who showed you where the dildo or sex toys Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 29 of 40 Page 54 1 JOHN ALESSI 2 were kept in the house the first time? 3 MR. PAGLIUSCA: Object to form and 4 foundation. 5 THE WITNESS: Nobody. Nobody show me. 6 BY MR. EDWARDS: 7 Q. You just saw it? 8 A. I saw it. 9 Q. So you knew where to put it back? 10 A. Yeah. We had to open the closet, clean 11 the closet, put the clothes in place, put the shoes 12 in place, put everything in place. So it was a 13 matter of tidying things up. 14 Q. Did you ever find any costumes? 15 A. I saw one shiny black costume, but I 16 didn't even know -- 17 Q. Where did you see it? 18 A. The same place. 19 Q. In Ms. Maxwell's closet? 20 A. Yes. 21 Q. And where was Ms. Maxwell's closet in the 22 house? 23 A. In the house? It was in the opposite side 24 of his bathroom. It was her bathroom in the master 25 bedroom. It was in the middle. So it was on the Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 30 of 40 GIUFFRE VS. MAXWELL Deposition LYNN TRUDE MILLER 05/24/2016 _______________________________________________________________________ Agren Blando Court Reporting & Video, Inc. 216 16th Street, Suite 600 Denver Colorado, 80202 303-296-0017 Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 31 of 40 Agren Blando Court Reporting & Video, Inc. LYNN TRUDE MILLER 5/24/2016 115 1 A Because I wasn't told any different. 2 Q Do you know where any -- any source of 3 that information came from? Was it Sky? 4 A It came from Sky. 5 Q Okay. And what do you recall him telling 6 you about when Virginia stopped working at 7 Mar-a-Lago? 8 A She was in a discussion with Mrs. Maxwell 9 to educate her and take her under her wing and be her 10 new momma. That's what I heard. 11 Q Okay. And who told you that? 12 A Sky. 13 Q Okay. And do you remember when Sky told 14 you that? 15 A I don't remember. 16 Q Okay. Did you learn anything else about 17 that, other than what you just said? 18 A No. 19 Q Okay. Do you know where she went to work 20 after Mar-a-Lago? 21 A I think she went with Mrs. Maxwell. 22 Q But do you know where, physically? 23 A Physically, Sky and I dropped her off one 24 day at Mrs. Maxwell's. I did not speak with 25 Mrs. Maxwell. I didn't have anything to say to her. Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 32 of 40 Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 21, 2016 9:17 a.m. C O N F I D E N T I A L Deposition of JOSEPH RECAREY, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 33 of 40 Page 29 1 JOSEPH RECAREY - CONFIDENTIAL 2 Ghislane Maxwell? 3 A. I wanted to speak with everyone related to 4 this home, including Ms. Maxwell. My contact was 5 through Gus, Attorney Gus Fronstin, at the time, who 6 initially had told me that he would make everyone 7 available for an interview. And subsequent 8 conversations later, no one was available for 9 interview and everybody had an attorney, and I was 10 not going to be able to speak with them. 11 Q. Okay. During your investigation, what did 12 you learn in terms of Ghislane Maxwell's 13 involvement, if any? 14 MR. PAGLIUCA: Object to form and 15 foundation. 16 THE WITNESS: Ms. Maxwell, during her 17 research, was found to be Epstein's long-time 18 friend. During the interviews, Ms. Maxwell was 19 involved in seeking girls to perform massages 20 and work at Epstein's home. 21 MR. PAGLIUCA: Object to form and 22 foundation. 23 BY MR. EDWARDS: 24 Q. Did you interview -- how many girls did 25 you interview that were sought to give or that Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 34 of 40 Page 30 1 JOSEPH RECAREY - CONFIDENTIAL 2 actually gave massages at Epstein's home? 3 MR. PAGLIUCA: Object to form and 4 foundation. 5 BY MR. EDWARDS: 6 Q. Approximately. 7 MR. PAGLIUCA: Same objection. 8 THE WITNESS: I would say approximately 9 30; 30, 33. 10 BY MR. EDWARDS: 11 Q. And of the 30, 33 or so girls, how many 12 had massage experience? 13 MR. PAGLIUCA: Object to form and 14 foundation. 15 THE WITNESS: I believe two of them may 16 have been -- two of them. 17 BY MR. EDWARDS: 18 Q. Okay. And as we go through this report, 19 you may remember the names? 20 A. Correct. Let me correct myself. I 21 believe only one had. 22 Q. And was that -- was that one of similar 23 age to the other girls? 24 MR. PAGLIUCA: Object to form and 25 foundation. Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 35 of 40 Confidential Page 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE NO. 15-CV-07433-RWS ------------------------------------------x VIRGINIA L. GIUFFRE, Plaintiff, v . GHISLAINE MAXWELL, Defendant. -------------------------------------------x June 3, 2016 9:07 a.m. C O N F I D E N T I A L Deposition of DAVID RODGERS, pursuant to notice, taken by Plaintiff, at the offices of Boies Schiller & Flexner, 401 Las Olas Boulevard, Fort Lauderdale, Florida, before Kelli Ann Willis, a Registered Professional Reporter, Certified Realtime Reporter and Notary Public within and for the State of Florida. Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 36 of 40 Confidential Page 18 1 DAVID RODGERS 2 flyer person, then you would reduce it to an 3 initial? 4 MR. PAGLIUCA: Object to form and 5 foundation. 6 MR. REINHART: You can answer the 7 question. 8 You can answer the question, if you can 9 answer the question. You are allowed to answer 10 t h e q u e s t i o n , i f y o u u n d e r s t a n d t h e q u e s t i o n . 11 B Y M R . E D W A R D S : 12 Q . I ' m t r y i n g t o u n d e r s t a n d y o u r t e s t i m o n y . 13 I s i t , i f y o u c a m e t o k n o w t h a t p e r s o n - - 14 A . U h - h u h . 15 Q . - - a s a f r e q u e n t f l y e r p a s s e n g e r , y o u 16 w o u l d b e g i n t o r e d u c e t h a t p e r s o n ' s n a m e t o a n 17 i n i t i a l a t s o m e p o i n t ? 18 M R . P A G L I U C A : S a m e o b j e c t i o n . 19 T H E W I T N E S S : W e l l , w e d o n ' t r e a l l y h a v e a 20 f r e q u e n t f l y e r p r o g r a m t h a t w e d o , s o t o s p e a k . 21 A l o t o f t i m e s I w o u l d d o i t b e c a u s e i f y o u 22 w o u l d w r i t e o u t e v e r y b o d y ' s n a m e t h e r e i s n o t 23 e n o u g h s p a c e , y o u k n o w , t o g e t e v e r y b o d y ' s n a m e 24 i n t h a t l i t t l e s q u a r e t h e r e . 25 Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 37 of 40 Confidential Page 34 1 DAVID RODGERS 2 Q. -- is that right? 3 And is that -- is Ghislaine Maxwell 4 somebody that through the years 1995 through 2013 5 was somebody who flew very frequently? 6 A. What were the years again? 7 Q. The years of this book, 1995 -- 8 A. I wouldn't say through 2013. But, yes, 9 '95 through 2000 sometime. Probably, I would have 10 t o g o b a c k a n d - - w e l l , y o u c a n s e e i n t h e r e . 11 Q . W e w i l l g e t t o i t . 12 A . T h e r e w i l l b e a p o i n t w h e r e y o u d o n ' t s e e 13 h e r m u c h . B u t t o s a y i t w e n t t h r o u g h 2 0 1 3 w o u l d n o t 14 b e a c c u r a t e . 15 Q . L e t ' s d o i t t h i s w a y : T h e p e r s o n t h a t y o u 16 h a v e r e f l e c t e d o n n u m e r o u s n o t a t i o n s - - 17 A . Y e s . 18 Q . - - t h r o u g h h e r e a s G M - - 19 A . Y e s . 20 Q . - - j u s t b y t h e i n i t i a l s , a r e w e a b l e t o 21 s a f e l y k n o w t h a t t h a t i s G h i s l a i n e M a x w e l l ? 22 A . Y e s . 23 M R . P A G L I U C A : O b j e c t t o f o r m a n d 24 f o u n d a t i o n . 25 M R . E D W A R D S : C o u r t r e p o r t e r , d i d y o u g e t Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 38 of 40 Confidential Page 35 1 DAVID RODGERS 2 the answer? 3 THE REPORTER: Yes. The answer came 4 before the objection. 5 BY MR. EDWARDS: 6 Q. So on the next flight, the next day, from 7 Palm Beach to SAF. Is SAF Santa Fe? 8 A. Yes. 9 Q. And it indicates JE and GM. 10 A r e w e a b l e t o t h e n k n o w t h a t t h o s e 11 p a s s e n g e r s o n t h a t f l i g h t w e r e J e f f r e y E p s t e i n a n d 12 G h i s l a i n e M a x w e l l ? 13 A . Y e s . 14 M R . P A G L I U C A : O b j e c t t o f o r m a n d 15 f o u n d a t i o n . 16 B Y M R . E D W A R D S : 17 Q . A n d w h e r e w o u l d y o u l a n d a t S A F ? I s t h a t 18 a n a i r p o r t ? 19 A . I t i s a n a i r p o r t . 20 Q . I s i t a p r i v a t e a i r p o r t ? 21 A . N o . I t ' s - - a i r l i n e s g o i n t h e r e . 22 Q . D i d J e f f r e y E p s t e i n a l s o h a v e a l a n d i n g 23 s t r i p a t h i s p r o p e r t y i n N e w M e x i c o ? 24 A . H e d i d a t o n e t i m e . 25 Q . W h a t w o u l d t h a t - - d o y o u r e m e m b e r w h a t Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 39 of 40 Confidential Page 36 1 DAVID RODGERS 2 that code would be? 3 A. I don't believe there was a code. 4 Q. All right. Were there times that you 5 landed either the Gulfstream or the Boeing -- 6 A. No. 7 Q. No. 8 MR. REINHART: Let him finish the question 9 before you answer. 10 T H E W I T N E S S : O h , I ' m s o r r y . 11 B Y M R . E D W A R D S : 12 Q . S u r e . W e a r e d o i n g f i n e s o f a r . B u t t h e 13 c o u r t r e p o r t e r i s t a k i n g d o w n a l l o f o u r q u e s t i o n s 14 a n d a l l o f o u r a n s w e r s . W e a r e c o m m u n i c a t i n g w e l l . 15 A . O k a y . 16 Q . B u t w h e n I g o t o r e a d t h i s b a c k , w e m a y 17 n o t g e t t h a t . 18 A . O k a y . G o a h e a d . 19 Q . S o w e r e t h e r e t i m e s w h e r e y o u l a n d e d o n e 20 o f J e f f r e y E p s t e i n ' s p l a n e s o n h i s p r i v a t e l a n d i n g 21 s t r i p a t t h e N e w M e x i c o p r o p e r t y ? 22 A . Y e s . B u t n o t t h e G u l f s t r e a m a n d n o t t h e 23 B o e i n g . 24 Q . W h a t p l a n e d i d y o u l a n d o n h i s p r o p e r t y ? 25 A . T h e C e s s n a 4 2 1 . A n d p r o b a b l y a Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 40 of 40